[DRAFT — requires legal review]
This page is a structural draft prepared for review. It is not legal advice and does not represent Factor4's final policy or binding commitments. Counsel must review, correct and approve every section before publication.
Privacy Policy
Effective date: [TODO: verify] · Last updated: [TODO: verify]
This draft describes how Factor4, LLC would handle information submitted through factor4giftcard.com. Scope, retention periods and rights language below are placeholders for counsel to confirm against Factor4's actual practices.
1. Information we collect
Information you submit through forms on this site: business name, your name, business email address, phone number and industry. Information collected automatically may include IP address, device and browser information, pages viewed and referring source. [TODO: verify] — confirm the full list of analytics and advertising tools in use and any data they collect.
2. How we use information
To respond to demo and quote requests, to contact you about a gift card or loyalty program, to provide and support services, to measure site and advertising performance, and to meet legal obligations. [TODO: verify] — confirm whether any automated decision-making or profiling occurs.
3. How we share information
Categories to confirm: service providers acting on our behalf (hosting, CRM, email, analytics, advertising), payment processors, ISO/ISV/VAR partners where a referral relationship exists, and disclosures required by law or in connection with a business transfer. [TODO: verify] — confirm each category, the named vendors, and whether any sharing constitutes a "sale" or "sharing" under state privacy laws.
4. SMS and telephone consent (TCPA)
Draft intent: by submitting a form with a phone number and checking the consent box, you agree to be contacted at that number by phone, and by text where offered, including through automated technology, about your inquiry. Consent is not a condition of purchase. Message and data rates may apply. Reply STOP to opt out of texts and HELP for help. [TODO: verify] — counsel must confirm the exact consent language, message frequency disclosure, opt-out handling, carrier disclaimers and whether SMS is actually used.
5. Cookies and similar technologies
Draft intent: this site may use strictly necessary cookies, analytics cookies and advertising cookies (including conversion measurement for paid search). [TODO: verify] — enumerate the cookies actually set, their purposes and durations, and confirm whether a consent banner is legally required for the audiences served.
6. Data retention
Draft intent: information is retained for as long as needed for the purposes described above and to meet legal, tax and recordkeeping obligations, then deleted or de-identified. [TODO: verify] — specify actual retention periods per data category.
7. Your rights and choices
Depending on where you live, you may have rights to access, correct, delete or port your information, to opt out of targeted advertising or the sale or sharing of personal information, and to appeal a denial. [TODO: verify] — confirm which state and international regimes apply, the verification process, response timelines and the submission channel.
8. Security
[TODO: verify] — describe the administrative, technical and physical safeguards actually in place. Do not publish a security claim that has not been verified.
9. Children's privacy
This site is directed to businesses and is not intended for children. [TODO: verify] — confirm the age threshold language.
10. Changes to this policy
We may update this policy and will revise the "last updated" date above. [TODO: verify] — confirm the notification method for material changes.
11. Contact us
Factor4, LLC
620 Parkway Drive, Suite 4, Broomall, PA 19008
1 (484) 471-3963
Privacy email: [TODO: verify]